Privacy

Livingcap Srl, with its Registered Office at Via Mirabella 51 36042 Breganze (VI), VAT Registration Number03165360243 (hereinafter to be called "Livingcap"), in its capacity as Controller of the Processing, pursuant to Article 13of Legislative Decree no. 196 of 30.6.2003 (hereinafter to be called the "Privacy Code") and to Article 13 of EURegulation 2016/679 (hereinafter to be called the "GDPR") informs you that your data will be processed in accordancewith the following purposes and procedures: 

1. Subject matter of the Processing
Livingcap will process personal and identifying data (for example, name, surname, company style, address, telephone, e-mail, bank and payment details – hereinafter to be called "personal data" or simply "data") communicated by you on theconclusion of contracts for Livingcap services. 

2. Purpose of the Processing
Your personal data will be processed without your express consent (Article 24, paragraphs a), b) and c) of the PrivacyCode and Article 6, paragraphs b) and e) of the GDPR), for the following Purposes of the Service:
- the conclusion of contracts for Livingcap services;
- compliance with pre-contractual, contractual and tax obligations deriving from the relations existing with yourself;
- compliance with the obligations imposed by law, the regulation, Community law or with an order of any Authority (as, forexample, in the field of anti-money laundering);
- the exercise of Livingcap’s rights such as the right to defend itself in proceedings.

3. Manner of Processing
The Processing of your personal data is carried out by means of the operations indicated in Article 4 of the Privacy Codeand Article 4.2 of the GDPR. More precisely, this will take the form of the collection, recording, organisation, storage,consultation, manipulation, amendment, selection, extraction, comparison, use, interconnection, blocking,communication, erasure and destruction of the data. Your personal data will be subject to both paper-based andelectronic and/or automated processing. Livingcap will process your personal data for the time required to comply with the purposes described above, and in any case for no longer than 10 years from the cessation of the relationship basedon the purposes of the Service.

4. Access to Data
Your data may be made accessible to the following for the purposes described in Article 2:
- Livingcap’s collaborators and staff in their positions as processing staff and/or internal Processors and/or systemadministrators;
- third party companies or other parties (including but not limited to banks, professional practices, consultants, insurancecompanies for the provisions of insurance services etc.) which carry out outsourcing activities for Livingcap, in theircapacity as external Processors.

5. Communication of Data
Livingcap will be able to communicate your data for the purposes indicated in Article 2, without the requirement forexpress consent (pursuant to Article 24 paragraphs a), b) and d) of the Privacy Code and Article 6 paragraphs b) and c)of the GDPR), to Supervisory bodies (such as IVASS, i.e. the Italian Institute for the Supervision of Insurance), Courts,insurance Associations for the provision of insurance services together with those parties to which communication isrequired by law for the implementation of the said purposes. The above parties will process the data in their capacities asautonomous processing Controllers. Your data will not be disseminated.

6. Security
The Data will be safeguarded and kept under control by means of the adoption of appropriate preventative securitymeasures, aimed at reducing to a minimum the risks of loss and destruction, unauthorised access, processing which hasnot been consented to and differing from the purposes for which the processing is carried out. 

7. Transfer of data
The management and storage of the personal data will be effected within the territory of the European Union.

8. Rights of the Data Subject
In your status as Data Subject you will have the rights described in Article 15 of the GDPR, that is: i. To receiveconfirmation of the existence or otherwise of personal data regarding yourself even if not yet recorded, and theircommunication in intelligible form; ii. To receive an indication: a) of the origin of the personal data; b) of the Purposesand manner of the Processing; c) of the logic applied in the case of processing effected with the assistance of electronicdevices; d) of the identifying details of the Controller, the Processor and of the designated representative pursuant toArticle 5.2 of the Privacy Code and Article 3.1 of the GDPR; e) of the parties or categories of parties to which thepersonal data may be communicated or which may obtain knowledge of the same in the capacity of designatedrepresentative in the country’s territory, of processor or of processing staff; iii. To obtain: a) the updating, rectification orsupplementing of the data; b) the erasure, transformation into anonymous form or the blocking of data processing incontravention of the law, including those whose storage is not necessary in relation to the purposes for which they werecollected or subsequently processed; c) confirmation that the operations described in letters a) and b) have been broughtto the knowledge, including with regard to their contents, of those to whom the data have been communicated ordisseminated save where such compliance is shown to be impossible or to require an expenditure of resources which ismanifestly disproportionate with respect to the right to be protected; iv. To oppose, in whole or in part and for legitimatereasons, the processing of the personal data regarding you even where relevant to the purpose of the collection. Whereapplicable, you will also have the rights described in Articles 16-21 of the GDPR (right of rectification, right to beforgotten, right to limit processing, right to the portability of the data and right of opposition), together with the right tomake a complaint to the Autorità Garante (the Regulatory Authority). 

9. Manner in which rights may be exercised
You will be able to exercise your rights at any time by sending a communication: 1. By e-mail to the address: info@livingcap.com 2. by registered letter with notice of receipt to : Livingcap Srl, Via Mirabella, 51 - 36042 Breganze (VI) 

10. Controller, Processor and processing staff
The Controller of the Processing is Livingcap Srl. The updated list of the processors and processing staff is kept, andmay be perused, at the Controller’s Registered Office.

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